Representatives of the Polish aviation and maritime sectors, supported by experts in energy, law and hydrogen technologies, are working on a joint position for the European Commission concerning the reform of the European Emissions Trading System (EU ETS). The initiative was launched by Mateusz Dziudziel, Director of Fuel Department at LOT Polish Airlines, who identified the urgent need to create a coordinated voice for mobile sectors in response to increasing regulatory burdens. The position is also co-authored by Żaneta Kłostowska, an expert leading work in the areas of technology, environment and innovation, who has significantly strengthened the substantive part of the initiative.

For the first time, representatives of air and maritime transport, as well as seaports, are combining their perspectives and competences, creating a unified and exceptionally strong voice. According to experts, such a signal – coming from two key EU transport sectors – has a real chance of being heard by the European Commission.

Why is a joint voice of the maritime and aviation sectors needed?

The extension of EU ETS to shipping and the tightening of rules for aviation have significantly increased the operational costs of transport companies. With EUA prices at EUR 60–70/t CO₂ (with historical peaks above EUR 100/t), every 100,000 tonnes of emissions generates EUR 6–7 million in additional annual costs.

Combining sectors under a joint initiative strengthens the industry’s negotiating position towards EU institutions, enables the presentation of consistent and interdisciplinary arguments, and increases the chances of introducing corrections to the ETS system leading to fair and proportionate solutions.

ETS implications for the European economy

The team of experts working on the position emphasizes that the current shape of ETS generates serious economic consequences: system costs are passed on to supply chains, service prices, goods and logistics, weakening the competitiveness of European companies; the risk of carbon leakage and business leakage is increasing, as operators increasingly consider relocating operations to ports and airports in Turkey, the UAE, the United Kingdom or North Africa, where regulatory burdens are lower.

Although ETS has generated more than EUR 230 billion in revenues, only a small portion of these funds has been allocated to transport decarbonization, which slows down the development of new fuels and infrastructure. Additionally, high EUA price volatility makes long-term planning more difficult and increases financing costs for decarbonization projects.

Experts emphasize that at least 30–40% of ETS revenues should be directed directly to the maritime and aviation sectors to finance their technological transformation. “I initiated work on the joint position because aviation and shipping need a coherent, unified voice in discussions with the European Commission. Joining forces between two strategic sectors creates a strong, substantive position that has a real chance of being heard in Brussels,” emphasized Mateusz Dziudziel, Director of Fuel Department at LOT Polish Airlines – initiator of the work.

 “From the very beginning I have co-led this initiative because effective transport transformation requires a comprehensive perspective – technological, legal and environmental. New fuels such as hydrogen, e-methanol or SAF can revolutionize the sector, but only if ETS supports them rather than blocks them. The joint voice of shipping and aviation is extremely powerful. The European Commission should hear that the industry is ready for transformation – provided that smart and proportionate frameworks are created,” said Żaneta Kłostowska, independent hydrogen technology expert, co-initiator and co-author of the position.

“The effectiveness of EU ETS depends on whether its costs translate into real technological change. This is why predictable rules and directing system revenues toward investments in fuels and infrastructure for shipping and aviation are so important. Effective transport transformation requires a coherent set of regulations: ETS should provide a price signal, while parallel fuel instruments should create a real market for new fuels. Our goal is to present a position to the European Commission that clearly shows that the current shape of ETS does not reflect the technological or economic realities of mobile sectors. Solutions are needed that link EU ETS with decarbonization financing in a proportionate way and support a level playing field,” said Beata Superson-Polowiec, Attorney-at-law / Partner, Polowiec and Partners Law Firm.

“From the energy market perspective, the current ETS is a structure that was originally designed to support decarbonization, but in practice increasingly acts like a tax burdening the most dynamic sectors of the economy. Shipping and aviation currently do not have access to cheap, zero-emission alternatives, while at the same time bearing the full cost of the system – without proportional investment support. If ETS is to fulfill its function, restoring balance between regulation and technological capabilities is necessary. EUA price stability, market predictability and real reinvestment of funds into the transformation of these sectors are essential conditions to avoid Europe losing competitiveness and business moving outside the EU,” said Paweł Piotrowicz, energy markets and hydrogen technologies expert at TÜV SÜD.

“Our duty is to maintain a high level of service for all carriers in maritime transport. For Polish ports to compete with other ports in Europe, necessary investments must be implemented, including those in decarbonization. We hope they will be co-financed from external sources. One of such sources could be ETS revenues. Without proper financing for decarbonization investments, European ports may lose competitiveness to ports located in countries with less restrictive regulations,” emphasized Alan Aleksandrowicz, Vice President for Finance and Security, Port of Gdańsk Authority.

“The maritime sector has long signaled the growing burdens related to ETS, but joining forces with the aviation sector creates a voice that the European Commission cannot ignore. This is not opposition to transformation – it is an appeal for regulatory common sense. For European companies to realistically invest in green technologies, ETS must become a supportive tool, not a limiting one. The joint position of two key transport sectors is a chance to introduce changes that will restore balance and ensure the competitiveness of the European economy,” summarized Janusz Czajkowski, CEO of SEA Global.

“From the perspective of a large industrial and energy entity, it is crucial that the EU ETS system genuinely supports transformation rather than merely generating costs. Aviation and maritime sectors are currently facing enormous investment challenges, comparable to the scale of transformation in industry and energy. Therefore, the initiative of a joint, cross-sector position – and in the next step its internationalization – is extremely important. Only a coordinated, data-driven voice can influence regulation in a way that ensures decarbonization is effective, technologically feasible and safe for the competitiveness of the European economy,” said Dr. Arkadiusz Kamiński, Executive Director for Environment, ORLEN SA.

Next steps – the position will become international

Further steps assume giving the position an international character – experts are currently working intensively to expand the initiative to include additional countries and European entities, in order to involve industry partners from other EU countries, European sector organizations and global aviation and maritime operators. The goal is to create the strongest possible coalition that will allow presenting the European Commission with a unified, well-argued proposal for changes enabling a real, fair and competitive energy transition in transport.

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